In the United States v. Rodgers case of 1893, the Supreme Court ruled on whether a U.S. marshal could be held liable for damages resulting from executing an arrest warrant in good faith but later found to be defective due to lack of jurisdiction by the issuing court. The defendant, Marshal Rodgers, had arrested one John Bad Elk upon a warrant issued by a justice of peace who did not have jurisdiction over crimes committed on Indian reservations where both parties were Native Americans. After being released, Bad Elk sued Rodgers for false imprisonment and won at trial level with $2,000 awarded as damages. The Supreme Court reversed this decision stating that if officers acted under color of their office without malice or intention to exceed their authority and believed they were acting correctly within it then they should not be punished for mistakes or errors in judgment made in good faith while performing official duties even when those actions are later determined unlawful due to technicalities such as lack of jurisdiction.

In the dissenting opinion for United States v. Rodgers, Justice Brewer argued that the majority's interpretation of federal law was too broad and could potentially criminalize innocent actions. He contended that while Rodgers did indeed lie about his identity to a government official, he had not committed fraud because there was no evidence showing that he intended to defraud or harm anyone by doing so. According to Justice Brewer, lying alone should not be considered a crime unless it is done with fraudulent intent or causes actual harm. He also pointed out inconsistencies in how different sections of the same statute were interpreted by the court and suggested this could lead to confusion and unfair application of the law.